**Facts:**
On January 4, 2005, Police Officer 3 (PO3) Louie Martinez received information from a confidential informant that Joseph Villasana, together with a certain Nida Villasana, was selling drugs on Hustisya Street, Valenzuela City. Consequently, a police task force was organized, consisting of PO3 Martinez and other officers, to conduct surveillance and arrest the alleged drug offenders.
At approximately 11:30 p.m. on the same day, the police team arrived at the mentioned location. They positioned themselves in three vehicles. Through the tinted windshield of their van, PO3 Martinez allegedly saw Villasana holding a plastic sachet while conversing with a woman. He moved towards Villasana discreetly, asked him not to discard the sachet, and confronted him after verifying its contents as shabu (methamphetamine hydrochloride). Villasana allegedly confessed the sachet was for personal use. He was then arrested and brought to the Marulas Barangay Hall for an inventory, where the item was marked “JCV.” The woman with Villasana managed to escape.
Villasana, on the other hand, claimed he was wrongfully apprehended while sitting inside a stationary jeepney. He asserted that police officers detained him and forcibly extracted P50,000 for his release, which his siblings failed to provide. He was taken to the Valenzuela City Hall and later to the Marulas Barangay Hall, where police presented the alleged drug evidence.
On October 28, 2010, the Valenzuela City Regional Trial Court (RTC) rendered its decision, finding Villasana guilty of violating Section 11 of Republic Act No. 9165 for illegal possession of dangerous drugs. The court sentenced him to imprisonment and ordered him to pay a fine.
Villasana appealed to the Court of Appeals (CA), arguing illegal arrest, compromised custody of seized drugs, and prosecution failure to establish his guilt beyond reasonable doubt. However, the CA affirmed the RTC’s ruling, dismissing his motion for reconsideration as well.
Villasana then filed a Petition for Review on Certiorari with the Supreme Court (SC), maintaining that the warrantless arrest was unlawful, thereby rendering the confiscated drugs inadmissible.
**Issues:**
1. Whether factual errors warranting a Rule 45 petition existed in the lower courts’ findings.
2. The validity of the warrantless arrest and subsequent admissibility of confiscated evidence.
3. Whether the chain of custody prescribed by Republic Act No. 9165 was properly observed.
**Court’s Decision:**
– **On the Right to Review:** The SC acknowledged its role to review factual findings when lower courts overlook facts affecting the outcome. In this case, the court saw sufficient grounds for factual review, given the lower courts’ misapplication of evidence on the in flagrante delicto arrest.
– **On Warrantless Arrest:** The SC found the warrantless arrest of Villasana invalid since PO3 Martinez’s viewing position and circumstances during the arrest did not satisfy the overt act requirement. Martinez did not have personal knowledge that a crime was being committed. Information from informants alone was insufficient to justify a warrantless arrest.
– **On Chain of Custody:** The SC held that the prosecution failed to establish an unbroken chain of custody. The drugs were not marked immediately upon seizure, were inconsistently marked, and lacked proper inventory and photographing as required by Section 21 of the Republic Act No. 9165.
Ultimately, these procedural failures and legal misapplications led to a reasonable doubt regarding the integrity and admissibility of the seized substance.
**Doctrine:**
Evidence obtained from an illegal warrantless arrest is inadmissible. Compliance with the chain of custody rules is mandatory to ensure evidence integrity. Failure to perform immediate marking, inventory, and photographing may prove fatal in securing convictions under the Comprehensive Dangerous Drugs Act.
**Class Notes:**
– **Key Concepts:** Warrantless arrest validity, chain of custody in drug cases, admissibility of evidence, reasonable doubt standard in criminal proceedings.
– **Statutory Provisions:**
– Article III, Section 3(2) of the Philippine Constitution
– Republic Act No. 9165, specifically Section 21
– **Principles:**
– In flagrante delicto arrest requires the execution of an overt act implicating imminent, actual, or attempted crime before the officer.
– Marking of seized evidence must be immediate and documented in the presence of the suspect.
**Historical Background:**
This case took place against the backdrop of the Philippine government’s intensified campaign against illegal drugs in the early 2000s, characterized by strict legislation under Republic Act No. 9165. The judiciary’s role was crucial in balancing national security interests with strict adherence to constitutional rights and legal procedures, particularly in upholding due process in criminal prosecutions of drug offenses.
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